Tax Allocation Agreements

On April 22, 2021, the Federal Reserve Board, FDIC, and OCC (the “agencies”) issued a notice of proposed rulemaking that would require banks that file tax returns as part of a consolidated tax filing group to enter into income tax allocation agreements with their parent companies and other members of the consolidated group that join in the filing, and would set forth specific requirements for the contents of those agreements.  The proposal would apply to all insured depository institutions and OCC-chartered uninsured institutions that are not registered as Subchapter S corporations (collectively, “covered institutions”).

Continue Reading Federal Banking Regulators Issue Proposal on Income Tax Allocation Agreements